Coronavirus (COVID-19) domestic vaccine certification: business and regulatory impact assessment
This BRIA considers the impacts for businesses and consumers of laying the Regulations under the Coronavirus Act 2020 to mandate the domestic use of Covid Vaccine Certification (referred to as 'Certification' hereafter) in higher risk settings.
Summary and recommendations
The Scottish Government's Strategic Framework includes a package of measures which, taken together, are designed to suppress transmission of the virus. Although daily Covid case numbers are dropping in Scotland, case numbers remain too high, and we still have a large susceptible population which could lead to cases rising again.
This BRIA has set out the relative costs and benefits of an amended certification option with addition of record of a negative covid test, compared against the certification option currently in place; both of which have the intended effect of reducing the risk of transmission, reducing the risk of serious illness and death thereby alleviating current and future pressure on the NHS, reducing the risk of settings specified in the scheme being required to operate under more restrictive protections, or to close; and increase the protection enjoyed by those using settings covered by the scheme and their contacts. Our assessment of the options has been informed as much as possible by engagement with the sectors in scope.
A summary of costs and benefits associated with the options is presented below in Table 4:
| Measure | Benefits | Costs |
|---|---|---|
| Option 1: Retain mandatory vaccine Certification in higher risk settings (current policy) | Sectors in scope continue to be characterised by many of the high risk factors associated with transmission of the virus. Certification is an additional means through which we can continue to reduce the risk of transmission. As such, it will mitigate the risk of closure and more restrictive measures, and consequent negative economic impact. This option would result in some public health benefit and would reduce the risk of infection and transmission of the virus and subsequent hospitalisations and pressure on the NHS. |
These include both direct costs of compliance with the regulations (staffing and infrastructure); local government monitoring and enforcement costs; potential losses of footfall and revenue arising from reduction of customer base for affected venues, particularly among younger demographics; cashflow impacts of requirements to provide refunds for ticketed events; business impact from cancellation or reduced scale of events. |
| Option 2: Retain mandatory vaccine Certification in higher risk settings (current policy) and expand Certification to include record of a negative test (LFD or PCR result) as an alternative to providing proof of vaccination | This option would result in the greatest public health benefit as it would reduce the risk of infection and transmission of the virus and subsequent hospitalisations and pressure on the NHS and would increase customers options to socialise, providing wider social benefit while offering them increased protection through vaccination and testing. Potential for reduced losses of footfall and revenue compared with those that could arise under Option 1, by incorporation of record of test results as alternative to proof of vaccination. Potentially important for businesses with larger share of younger demographics in customer base, who currently have lower vaccination rates. The inclusion of testing could potentially be perceived by some customers as reducing risk within specific premises. , potentially supporting footfall. |
There would be no additional costs on businesses within scope directly associated with implementing this option, relative to Option 1, as is an alternative check to the NHS Scotland Covid Status app/PDF or paper certificate, rather than an additional check. There is a risk with this option that customers perceive the addition of testing as creating more risky environments as vaccination is no longer being incentivized. This could lead to loss in revenue through a small reduction in footfall, attendance and an increase in cancellations. |
We conclude that Option 2 – the retention of mandatory vaccine Certification in higher risk settings (current policy) and an expansion to include record of a negative test - is a necessary and proportionate response, alongside an effective baseline of public health measures, which will best meet our policy objectives. Monitoring and evaluation will inform implementation as well as regular review (at least once every 21 days) of the Regulations to determine whether any less intrusive alternative measures could be introduced to achieve the same combination of policy objectives in respect of the higher risk sectors concerned.
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